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Home My WebLink About02-3418 ANDREW S. LORENZ, Plaintiff v, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA ... t. NO, tJ;)'3Wf tu:J MELISSA L. LORENZ, Defendant CIVIL ACTION - LAW IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take prompt action, You are warned that if you fail to do so, the case may proceed without you and a Decree of Divorce or annulment may be entered against you by the Court. A judgment may also be entered against you for any other claim or relief requested in these papers by the Plaintiff, You may lose money or property or other rights important to you, When the ground for divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the office of the Prothonotary , IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM, YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE, IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP, Court Administrator 4th Floor, Cumberland Counly Courthouse Carlisle, PA 17013 717-240-6200 ANDREW S, LORENZ, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA v, : NO, (>2- J r I iT : CIVIL ACTION - LAW : IN DIVORCE MELISSA L. LORENZ, Defendant COMPLAINT UNDER SECTION 3301(c) OR 330J(d) OF THE DIVORCE CODE 1. Plaintiff is ANDREW S, LORENZ, currently residing at 60 Winter Lane, Enola, Cumberland County, Pennsylvania 17025, 2, Defendant is MELISSA L. LORENZ, currently residing at 101 East Main Street, Camp Hill, Cumberland County, Pennsylvania 17011, 3, Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six (6) months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on November 18, 2000 in Cumberland County, Pennsylvania, 5, Plaintiff avers that there are no children of the parties under the age of 18, 6, There have been no prior actions of divorce or for annulment between the parties, 7, Neither of the parties in this action is presently a member of the Armed Forces, 8, The Plaintiff and Defendant are both citizens of the United States, 9. Plaintiff has been advised of the availability of marriage counseling and that he may have the right to request that the Court require the parties to participate in counseling prior to a divorce decree being handed down by the Court, COUNT I - DIVORCE 10, Paragraphs I - 9 are herein incorporated by reference, 11, The Plaintiff avers that the grounds on which the action is based are as follows: (a) That the marriage is irretrievably broken, WHEREFORE, Plaintiff requests the Court to enter a Decree of Divorce, Respectfully submitted, ,y;/H/K'{' , tV ~ , .JtNNIFE 1. LEHMAN, ESQUIRE Attorney I,D, #52784 27 South Arlene Street P,O, Box 6130 Harrisburg, P A 17112 (717) 671-1200 Date: 7//7/0;J I , VERIFICATION I verifY that the statements made in the foregoing Complaint in Divorce are true and correct to the best of my knowledge, information and belief, I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. 9 4904 relating to unsworn sification to authorities, Date: t::r!or--- f ~~ " ~ ~ ~ -.J ~ ~ o c s: -ClJ) mrr Z~J' zt (fJ ;,," r~ ~.~. ~c; ~F~ :J>c' ~ ~ ~::--... ~ &'~ ~ \ ~ :' \ \ ~ ~ ~ a f'.' <- r- r= n~ ":"7-: ,,,~,,. Co .'-;8 ). ~; ,._,1 ~ ~~~ ~-j;~ '''' ~ ANDREW S. LORENZ, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA v. NO. 02-3418 CIVIL MELISSA L. LORENZ, Defendant CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF SERVICE I, JENNIFER L. LEHMAN, ESQUIRE, do hereby certify that a true and correct copy of a Complaint Under Section 3301(c) or 3301(d) of the Divorce Code was served upon the Defendant, . MELISSA L. LORENZ, by certified mail, restricted delivery, on the 20th day of July, 2002. The original signed return receipt, number 7000 0600 0028 3366 9976, is attached hereto and made a part hereof. Respectfully submitted, ~~c1~AA/ JE . ER L. LEHMAN, ESQUIRE Supreme Court J.D. #52784 P.O. Box 6130 27 South Arlene Street Harrisburg, P A 17112 (717) 671-1200 Date: 7~~ S-O~ '--'~-'''....,~~....~._.._''~"...__.~,~-~~--._... . . ,> · Complete Items 1, 2, and 3, AJ80 ~ Item 4 If Reetrtcted Delivery Is desired. · Print your nlllTl8 and adc:lIlIIIS on the reverse so that we can return the card to you, · Attach this card to the back of the ma/lplece, or on the front If space permits, 1, ArtIcle Add-.ed 10: MELISSA L. LORENZ 101 EAST MAIN STREET C["P HILL PA 17011 2, Article Number (rransfer /tom service label) iPs Form 3811, August 2001 7000 O~pOtJ()28 3366 ~ir(~ Receipt 3. ServIce 1YPe !I CertifIed Md CJ ~ Mall CJ Regl8lered CJ Return "-PI ~ Merchandise , CJ Il'lIUNd Mall CJ C.Q,D, ~..,.. , '. 9976 ~. ~ ~ ~95-o1-M-0381 . '-, ANDREW S, LORENZ, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v, DOCKET No, 02-3814 MELISSA L. LORENZ, DEFENDANT CIVIL ACTIOJ\ -LAW PETITION TO WITHDRAW ApPEARANCE AND NOW, COMES Richard C, Gaffney, Esquire and SMIGEL, ANDERSON AND SACKS, LLP (individually and collectively referred to herein as "Attorney"), counsel of record for the Defendant/Respondent, Melissa Lorenz (hereinafter "Client"), who petitions this Honorable Court under Pa.R.Civ,P. Rule 1012 (b) for leaVt: to withdraw appearance as counsel, and who, in support thereof, aver the following: I, Attorney and Client have developed significant philosophical differences related to matters concerning the prosecution and handling ofthe case, 2. At this point in the attorney-client relationship, it is impossible for Attorney to adequately represent Client's interests. 3, Neither of the parties will be prejudiced by Attorney's withdrawal from this case, 4, Attorney contacted Client and Client does not oppose said Petition to Withdraw Appearance, See, Exhibit A, Client's Authorization to Withdrawal of Counsel. 5, Attorney contacted Counsel for the plaintiff, Jelmifer Lehman, Esquire, and Plaintiff's counsel consented to Attorney Withdrawal of Appearance. See, Exhibit B, WHEREFORE, Attorney respectfully prays this Honorable Court for leave to withdraw appearance in the above-captioned action, Respectfully submitted, \1- ~)-_\}'J~~CS-- Richard C, Gaffney, Esquire Supreme Court I.D, No, 63313 SMIGEL, ANDERSON, & SACKS 4431 North Front Street Harrisburg,PA 17110 (717) 234,2401 ANDREW S. LORENZ, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v, DOCKET No, 02-3814 MELISSA L. LORENZ, DEFENDANT CIVIL ACTION-LAW CERTIFICATE OF SERVICE The undersigned hereby certifies that on November 17,2003 the attached Petition to Mark Rule Absolute was served on the Respondent, Melissa Lorenz, in accordance with Pennsylvania Rules of Civil Procedure by postage prepaid United States Certified Mail, at the following address: Melissa Lorenz 101 South Locust St. Camp HilI, PA 17011 And also on counsel for the Plaintiff at the following address: Jennifer L. Lehman, Esquir,e PO Box 6130 27 South Arlene Street Harrisburg, PA 17112-0130 ANDREW S, LORENZ, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA v CASE No, 02-3814 MELISSA L. LORENZ, DEFENDANT, CIVIL ACTION - LA W - IN DIVORCE AUTHORIZATION FOR WITHDRA WL OF COUNSEL AND NOW, thisd:r: day of October 2003, the undersigned, Melissa L. Lorenz, hereby authorizes her counsel of record, Richard C. Gaffuey, Jr., MBA, Esquire and Smigel, Anderson & Sacks, LLP to withdraw as counsel in the above-captioned matter.. Respectfully submitted, 9lu a~ ~ Melissa L Lorenz, Plaintiff Jennifer 1. Lehman ~~1 ~--- Attorney at Law November 11,2003 Richard C, Gaffney, Esquire Smigel, Anderson & Sacks 4431 North Front Street Harrisburg, PA 17110 RE: Andrew S, Lorenz v, Melissa L. Lorenz No, 02-3418, In Divorce Dear Richard: I will not oppose your Petition to withdraw your appearance, Nonetheless, I would appreciate if your client would respond to my letter of June 5, 2003, along with the enclosed proposed Agreement, Ifwe do not hear from her by December 15,2003, we will have no choice but to file for a divorce master, As I am sure you have made her aware, the process of going through the divorce master will just cause additional expenses to both parties, neither of which have the money to exercise that option, It would be a shame to see money going for attorneys' fees when it could be utilized for the payment of the joint debt or current living ,expenses, Unfortunately, your client's inaction has left my client with no choice but to do this, as an economic resolution is necessary prior to a divorce, I await your Petition along with a response from yOill' client, Sincerely, f' i'v ~v..fc ,} Jennifer L, Lehman 1" . ,;/.1/F7':..'.....-' ; ,~'.....-' JLL:lsf cc: Andrew S, Lorenz P,O, Box 6130.27 South Arlene Street- Harrisburg, PA 17112_0130.717-671-1200 - telecopier 717-671-9601 (') (""".:) (-.j c c -~' r ~ -- "TJi]'.r ~) nv. ".,~ "/:] ZC' (..;:::; 0).' ~ r;:c: ) ;e: r-\ ?i> 1'0 ) >-c:: -c-! 2: :".) -j ~n -, (J) -< 'Y NOV 2 0 2003 "h" ANDREW S, LORENZ, PLAINTIFF v, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA "l,ll\~ DOCKET No, 02~ MELISSA L. LORENZ, DEFENDANT CIVIL ACTION -LA W ORDER AND NOW, this 2'- day of November 2003, a Rule is issued upon the Defendant, Melissa Lorenz, to show cause why the relief sought in the attached Petition to Withdraw Appearance should not be granted. Rule Returnable 10 days after servIce, BY THE COURT: ,/ d , J. ~ J\ \,c).? \\0- ViN\/j\:1,tSNN:ld 1'.I,e.v '1"'" '''''!In'"' ;'\.'. \i: !' " ; " .' r::--~~,_;:, \ \ v t:i; :,; I"L,j ,',\...0 I Z liON 80 A'tN.U}--'~~~":i':'<-J" :10 :<:;\:l::'()-~J-:'fi.U v, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA 34\'-6 DOCKET No, 02-3"lH-4- 'r ANDREW S, LORENZ, PLAINTIFF MELISSA L. LORENZ, DEFENDANT CIVIL ACTION - LA W ORDER AND NOW, this PI'day of December 2003, upon consideration of Attorney's Petition to Withdraw Appearance, Respondent's failure to file an Answer thereto and Attorney's Petition to Make Rule Absolute, it is ORDERED that the Rule is made Absolute. Attorney is granted leave of court to withdraw appearance within ~ days of this Order. All proceedings to stay meanwhile to afford Respondent an opportunity to obtain other counsel. BY THE COURT: ~./lJi / , ], ~6' \~\ \.'ir;\;>rU.SI\}U~k1 AlNr;r_'t":: I I :. J !lIlt L J :.)]0 WOZ ""'/('h'!U'" 'IOu, :JUJ::10 ;'1,0\'.........,,, 1"1 U,:J -lf1.J.. 3Jf:i:.i()"{]31!:1 ANDREW S, LORENZ, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v, DOCKET No. 02-3418 MELISSA L. LORENZ, DEFENDANT CIVIL ACTIOl\ -LAW PRAECIPE TO WITHDRAW ApPEARANCE To the Prothonotary of Said Court: Pursuant to Judge Hess' December 17,2003 Order granting the undersigned counsel leave of Court to withdraw as counsel to the Defendant, Melissa L. Lorenz, please withdraw my appearance as Ms, Lorenz' counsel. Respectfully submitted, :::~::~~ Supreme Court LD. No. 63313 SMIGEL, ANDERSON, & SACKS 4431 North Front Street Harrisburg, PA 17110 (717) 234,2401 ,.." c:::." c.~.::> .c- <-- J>" :;?-: N ~.~ o "'n -.\ :r:..." ;l~\ ~:~~""?, . __n ,~),(') ,~~,-, rTI '-~\ ,.;? !'-' U;, <.:; ':-r; ANDREW S, LORENZ, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v, : NO, 02-3418 MELISSA L. LORENZ, Defendant : CIVIL ACTION - LAW : IN DIVORCE Date: rt~~~J ~w) f fru,rJ~ MELISSA 1:. LORENZ DEFENDANT AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under ~3301(c) of the Divorce Code was filed on July 18, 2002, 2, The marriage of the Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service of the Complaint. 3, I consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree, I verify that the statements made in this affidavit are lrue and correct, I understand that false statements herein are made subject to the penalties of 18 Pa, C.s, ~4904 relating to unsworn falsification to authorities, 'c-:') (-:,::) ~'\ ...."" ~:~. -;,j () "1.1. --- --' .....;') (~~? .- c.f. - ----- ANDREW S, LORENZ, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa, C.S, 94904 relating to unsworn falsification to authorities, v, : NO, 02-3418 CNIL MELISSA L. LORENZ, Defendant : CNIL ACTION - LAW : IN DNORCE AFFIDAVIT OF CONSENT !. A Complaint in Divorce under 9330I(c) of the Divorce Code was filed on July 18, 2002, 2, The marriage of the Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service of the Complaint. 3, I consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree, Date: '3/1~05 ~_,~l () ',..~::-, ' i"l (i5~ ~. :;0 ...- -' -".:.1, -- <.n - ANDREW S, LORENZ, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v, : NO, 02-33418 Date: '3jIJ/O; MELISSA L. LORENZ, Defendant : CIVIL ACTION - LAW : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER g3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a fmal decree of divorce without notice. 2, I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses in do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the prothonotary, I veritY that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa, C,S, 94904 relating to unsworn falsification to authorities. 0. C.:''7- r,'\ '~ii ::.J -','-. (,~"? -- (.n - ANDREW S, LORENZ, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA Date: d - aL/- 05' '\ ~fYV UMl,~ dlmn MELISSA L. LORENZ ~ DEFENDANT v, : NO, 02-3418 MELISSA L. LORENZ, Defendant : CIVIL ACTION - LAW : IN DIVORCE WAIVER OF NO'11CE.OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER ~3301(c) OF THE DIVORCE CODE 1, I consent to the entry of a final decree of divorce without notice, 2, I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if! do not claim them before a divorce is granted, 3, I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the prothonotary, I verify that the statements made in this affidavit are true and correct, I understand that false statements herein are made subject to the penalties of 18 Pa. C,S, ~4904 relating to unsworn falsification to authorities, (;\ (-:-? -- (.)" ANDREW S. LORENZ, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA Date: 3 JJ. - oS Plaintiffs Social Security No, 203-58-0457 1:;~u~. ~~ ) Je ifer 1. Lehman, Esquire Attorney for Plaintiff v. : NO. 02-3418 MELISSA 1. LORENZ, Defendant : CIVIL ACTION - LAW : IN DIVORCE PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Transmit the record, together with the following information, to the Court for entry of Divorce Decree: 1. Ground for Divorce: Irretrievable breakdown under ~3301(c) of the Divorce Code, 2. Date and Manner of Service of Complaint: Service was accepted by the Defendant on the 20th day of July, 2002, pursuant to an Affidavit of Service filed July 26, 2002, 3. Date of execution of the Affidavit of Consent required by 9330I(c) of the Divorce Code: by Plaintiff March 12, 2005; by Defendant February 24, 2005. 4, Related Claims Pending: All other claims have been withdrawn by either party, 5, Date Plaintiffs Waiver of Notice in 9330I(c) Divorce was filed with the prothonotaty: Dated March 12, 2005 and filed March 17, 2005, Date Defendant's Waiver of Notice in ~3301(c) Divorce was filed with the prothonotary: Dated February 24,2005 and filed March 17, 2005, Defendant's Social Security No. 196-66-4133 ~ ~ ,:. ~ N N 2 ~ -00:' flH1-~ 'Z-::r? :;::1.'-'. if';.:: ~",:: .;::C ?;:C, ~... '-, ::t:..0 ~c..:: z ::L ----- (;i?, ~-n (\1r: -ot!), ~1J'-" '3(:) :~1:~~ ~;3B ~~'rt\ ~ ~ .4 ""Q '$ o .s::- c,,:t - . "':+: + l: '*' +:+:;t;;t':f;;t' +.;+: +.'!; +. +. -t. +.'+':+ +.:+ +. +. 'f +. +. +. +:+: +.:+: +:+: ++ ++ :f.+. +.+ ++ +:+ '" +.;+: ~++++++++++++ ++++++ . . . . . . . . . . . . . . . . . . . . " " . . . " . " . . . . . . . . . . . . . . " " . " . " . " " . . . . IN THE COURT OF COMMON PLEAS ANDREW S. LORENZ, STATE OF PENNA, plaintiff No, 02-3418 VERSUS MELISSA L. LORENZ, Defendant DECREE IN DIVORCE AND NOW, ...yY) iVc.J.. :Ic)~ 2005 , IT IS ORDERED AND DECREED THAT ANDREW S. LORENZ , PLAINTIFF, AND MELISSA L. LORENZ , DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY. THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; . " . . . . . AJ( ut: " . " " . " . " . . . . . " . +++++++++ +++++++++++++++ ++. By THE C07;.J " . . . . " . . . . . . . . . . . . . Of +. Of +. 'f +: T '" +.;f +. +. 'f +,;f + 'f Of: + + Of. '1:+ UffI! CLmpixm ~ PROTH<I~~JA~' . . . " " .. ;1;++++ Of";;+: ++++ ++;+:'to . . . . . . . . . . . . " . . . . . . . . " . . . . . . . . . . . . . " . . . . " " " " " " " " " " " " " " " " " " " " " " " " " " " " " " " " " " " " " " " . " ,~:t' ~ 7fhSO<?['[' ~ r ~ firk? pi? ,Wo<"'F -